Offshore Gambling Explained

Curacao operated a master-licence framework from 1996 through 2024 - four master licences (the 1668/JAZ, GLH-OCCHKTW, 8048/JAZ, 1668/JAZ-2) each sub-licensed dozens of operators with minimal direct supervision. This system is winding down under the National Ordinance on Games of Hazard (NOOGH) and the new Curacao Gaming Control Board (CGCB) is issuing direct licences in its place. Anjouan (Comoros) emerged as a Curacao alternative in 2024. Kahnawake (a Mohawk Territory in Quebec) operates one of the longest-standing First Nation gaming-control frameworks. Costa Rica and the Philippines POGO regime served as alternative offshore frameworks at various points.

An offshore licence permits the operator to incorporate, open a payment account (with PSPs willing to accept the licence), and represent itself as licensed - but it does not permit the operator to advertise into regulated markets where local licensing is required, to use major payment rails in those markets, or to use major sports-rights partnerships. The licence is therefore primarily useful for traffic from markets without local licensing requirements - the diminishing 'grey market' set.

Three pressures: (1) regulated markets (UK, Germany, Netherlands, Italy, Spain, Sweden) increasingly enforce against offshore advertising into their borders, with ISP-blocking, payment-rail blocking, and operator-disgorgement penalties; (2) banks and payment processors face their own AML obligations and increasingly will not process offshore-licensed flows that touch regulated-market customers; (3) sports rights holders and media partners increasingly restrict their inventory to locally-licensed operators only. The result: offshore licences serve a shrinking total addressable market.

Offshore licensing remains the practical option for operators serving genuinely unregulated markets, for crypto-native operators where fiat banking rails are not in scope, and for technology suppliers (B2B aggregators, RNG providers) whose licence requirement is jurisdiction-of-incorporation only. The cost-benefit calculation is operator-specific; the per-jurisdiction implications are documented on the Regulatory Map.